The appellant suffered abuse from her husband for years. After one violent evening, she went to bed thinking about her husband’s behaviour and couldn't sleep. She went downstairs, poured petrol into a bucket, lit a candle, went to her husband’s bedroom and set it on fire. He died from his injuries. Ahluwalia pleaded manslaughter on grounds that she didn't intend to kill him, only to inflict pain. She also pleaded provocation on grounds of her treatment. D was convicted of murder and appealed.